What are the most urgent regulatory deadlines compliance managers should prepare for in Q4 2025?

Key upcoming dates include California’s EPR packaging reporting deadline (November 15, 2025) and the EU Deforestation Regulation compliance deadline (December 2025). Both require supplier data collection and verified reporting. Other extended timelines, such as PFAS reporting under TSCA (April 2026) and due diligence obligations under the EU Batteries Regulation (August 2027), should also be factored into long-term planning.

How should manufacturers approach PFAS phase-outs and evolving chemical reporting laws?

Manufacturers should audit their supply chains to identify where PFAS are used in coatings, components, or packaging, and begin developing alternative materials to avoid disruptions. They should also track changes under TSCA Section 8(a)(7) and state-level PFAS bans (such as those in Minnesota and Illinois). Because some PFAS reporting requires historic data dating back to 2011, early data collection is essential to stay compliant and reduce the risk of non-compliance penalties.

What practical steps can compliance managers take to stay proactive amid these changes?

To stay ahead, compliance managers should:Engage suppliers early to collect accurate, complete data.Centralize compliance records using digital tools that track regulations and reporting requirements.Monitor updates from agencies like the EPA, ECHA, and state authorities to anticipate shifts.Prioritize high-risk areas including PFAS, packaging EPR, and EU product sustainability rules to mitigate costly redesigns or delays.These steps help organizations maintain compliance resilience even as global regulations expand.

Why aren’t Safety Data Sheets (SDS) sufficient for product compliance?

Safety Data Sheets play an important role in communicating chemical hazards, but they were never designed to prove product compliance. Their scope is limited to hazard communication for substances and mixtures, not finished goods or complex assemblies. Because SDSs vary by region and often omit proprietary or low-percentage substances, they rarely provide a complete picture of what’s inside a product. Manufacturers that rely on SDSs alone risk incomplete data, manual verification work, and exposure to regulatory non-compliance as regulations expand.

What causes Full Material Disclosures (FMDs) to become unreliable over time?

Full Material Disclosures can initially seem comprehensive, but their accuracy fades quickly. Supplier formulations change, regulatory lists evolve, and proprietary holdbacks can conceal substances that later become restricted. Since FMDs are typically snapshots in time rather than living compliance documents, they can become outdated long before the next reporting cycle. Without a process to continuously update and validate these records, organizations face stale data and blind spots that complicate audits and customer requests.

How can companies close the compliance gap between SDS and FMD data?

Closing the gap requires a hybrid, data-driven approach. Instead of depending solely on SDSs or FMDs, leading compliance teams combine regulatory declarations, supplier engagement, and automation to maintain accuracy and coverage. This strategy treats material data as a living system — updated, validated, and traceable across the product lifecycle. The result is a more resilient compliance posture, enabling organizations to adapt as regulations, materials, and markets change.

Why are compliance data requests getting harder to manage?

They’re growing in both volume and complexity. Regulations like PFAS, REACH, and RoHS continue to evolve, often with little notice, and customers frequently ask for slightly different data in unique formats. The result is constant rework and very little time to keep up — even for the most organized teams.

What are the main risks of relying on manual processes?

Manual tracking through spreadsheets or email introduces both inefficiency and risk. It’s easy for information to get lost, duplicated, or outdated between submissions, and even a single missed update can delay a customer response or cause non-compliance. Over time, these small issues add up to slower workflows and higher stress for compliance teams.Common issues include:Missed regulatory or customer updatesVersion control errorsInconsistent or incomplete data across requests

How can technology make compliance work more efficient?

The right tools help by centralizing requests, automating routine tasks, and reusing data instead of starting from scratch every time. A platform can store your declarations once, apply them to multiple customers, and update automatically as regulations change.For example:Declarations can be reused across customers and product lines.Regulatory updates are applied automatically within the system.Teams spend less time managing spreadsheets and more time focusing on strategic work.

How does the Assent Sustainability Platform support suppliers?

Assent’s platform brings compliance management into one system. It shows all your requests in one place, keeps regulatory content up to date, and lets you reuse declarations across customers. By simplifying the process, it helps suppliers stay responsive, confident, and compliant even as demands continue to grow.

CSRD Reporting: Stop-the-Clock Omnibus Proposal Approved

On April 14, 2025, the EU Council approved the Omnibus 1 centered around the Stop-the-Clock mechanism included in the Omnibus Simplification Package. This mechanism, proposed by the European Commission in February 2025, postpones the effective deadlines for large companies and small and medium-sized enterprises (SMEs) that have not yet started reporting under the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CS3D).

Now approved, the Stop-the-Clock will be published in the EU Official Journal and come into force the next day. It pushes back:

The start date for CSRD reporting by two years for second- and third-wave companies
The transposition deadline and the first phase (covering the largest companies) of the CS3D by one year

What Should You Do Now? Don’t Wait

The CSRD and CS3D aren’t going away. This Stop-the-Clock reprieve is designed to help EU legislators agree on how to streamline and simplify CSRD reporting, and the CS3D and Carbon Border Adjustment Mechanism (CBAM). Although the proposed Omnibus Simplification Package reduces requirements on manufacturers, supply chain sustainability due diligence remains a core due diligence element across the EU.

This means that manufacturers should still be engaging their value chains for sustainability performance data. Right now is the time to ensure you have a program in place and a platform that centralizes all that data. Because of the extension, companies will likely face extra pressure to report fully and on time.

We recommend that you put a broad supply chain sustainability program in place rather than focus only on specific CSRD requirements. This way, you can recycle information for other mandatory sustainability reports.

What is the Omnibus Simplification Package?

On February 26, the European Commission released proposals for its first Omnibus Simplification Package — a major move to reduce complexity in sustainability regulations while staying aligned with Green Deal goals. In addition to proposals to streamline the CSRD, CS3D, and CBAM, the Omnibus Simplification Package comes with a draft Taxonomy Delegated Act.

The aim: Simplify EU rules, cut administrative costs, and unlock billions in investment. The European Commission estimates potential savings of €6.3 billion annually in compliance costs, and an additional €50 billion in public and private investment capacity.

Businesses, especially SMEs, have long voiced frustration with overlapping directives and high compliance costs. In response, the European Commission is targeting a 25% cost reduction for large companies and 35% for SMEs. By streamlining these rules, the EU hopes to make sustainability compliance more efficient and impactful.

Are Non-EU Companies Affected?

While the surface-level focus of the CSRD is on EU entities, its influence on non-EU companies shouldn’t be underestimated. Companies with operations or partnerships in the EU are already feeling the ripple effects of the directive. They face a rising demand for sustainability information and due diligence practices that align with the CSRD.

Manufacturers serving in-scope EU customers will need to collect and provide the necessary data to support CSRD reporting. Otherwise, they’re putting their business relationships and bottom lines at risk.

The recommendation to implement a broad supply chain sustainability program also applies to non-EU companies that aren’t in scope themselves. By collecting a broad range of sustainability data, companies will have the information needed to respond to customer CSRD surveys and be proactively prepared for North American mandatory reporting initiatives, such as the U.S. Securities and Exchange Commission (SEC)’s Climate-Related Disclosure Standards and the California climate disclosure laws.

How to Get Started

Assent can help you launch your supply chain sustainability management program. Our AI-powered platform automates supplier engagement for environmental and social impact data, plus it provides enhanced supplier screening to identify the risks that surveys alone can’t catch. And our CSRD Materiality solution can help you simplify your materiality assessment to understand which value chain entities and sustainability topics are most relevant to your requirements.

This Stop-the-Clock grace period is the perfect opportunity to get ahead of your CSRD data collection. Don’t let it go to waste: Book a demo of Assent’s solution today.

FAQ: EU Omnibus Simplification Package

Learn about the Stop-the-Clock Mechanism with answers from our experts.

What is the Stop-the-Clock mechanism in the EU Omnibus Simplification Package?

The Stop-the-Clock mechanism delays the reporting deadlines under the CSRD and CS3D. It gives large companies and listed SMEs more time to prepare by pushing back CSRD reporting for second- and third-wave companies by two years and delaying the CS3D start date by one year.

Does the Stop-the-Clock mean companies can pause CSRD or CS3D preparation?

No. The directives still apply, and companies should continue building their sustainability data programs. The delay offers time to simplify processes — but reporting requirements remain.

Are non-EU companies affected by the CSRD or CS3D delays?

Non-EU companies with EU customers or operations still need to collect supply sustainability data. The timeline postponement gives non-EU companies more time to get their sustainability programs in order.

Jamie Wallisch

Sustainability Expert

Jamie’s area of expertise is media monitoring, with a specialization in indirect screening and responsible sourcing. She helps companies proactively analyze their supply chains for adverse media mentions, Read More

Steven Andrews | Senior Regulatory Expert

Steven helps companies understand environmental regulations and how they are enforced. He is an internationally recognized expert, with more than 20 years of experience in EU policy development focusing on sustainability, product, waste, and recycling legislation. As the former Deputy Head of the Re...